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The Honorable Benjamin H. Settle Courtesy Copy of Electronic Filing for Chambers 2 Case No

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The Honorable Benjamin H. Settle Courtesy Copy of Electronic Filing for Chambers 2 Case No 1 The Honorable Benjamin H. Settle Courtesy Copy of Electronic Filing for Chambers 2 Case No. 3:09-cv-05456-BHS Exhibit to Plaintiffs’ Brief in Support of Summary Judgment 3 4 5 6 7 8 9 10 11 12 Exhibit 4 13 14 15 16 Part 1 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit to Pls.’ Br. in Supp. BOPP, COLESON & BOSTROM of Summ. J. 1 South Sixth Street (Case No. 3:09-cv-05456-BHS) Terre Haute, Indiana 47807-3510 (812) 232-2434 Case 3:09-cv-05456-BHS Document 210-1 Filed 06/29/11 Page 1 of 100 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Exhibit 4 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit to Pls.’ Br. in Supp. of Summ. J. BOPP, COLESON & BOSTROM (Case No. 3:09-cv-05456-BHS) 1 South Sixth Street Terre Haute, Indiana 47807-3510 (812) 232-2434 Case 3:09-cv-05456-BHS Document 210-1 Filed 06/29/11 Page 2 of 100 1 2 3 4 5 6 7 8 United States District Court Western District of Washington 9 Tacoma Division 10 11 John Doe #1, et al., No. 3:09-CV-05456-BHS 12 Plaintiffs, The Honorable Benjamin H. Settle v. 13 First Declaration of Jared Haynie in Sam Reed, et al., Support of Plaintiffs’ Motion for Summary 14 Judgment Defendants. 15 16 17 18 I, Jared Haynie, make the following declaration pursuant to 28 U.S.C. § 1746: 19 1. I am an attorney of law licensed to practice in the State of Colorado. 20 2. I am an attorney at the law office of Bopp, Coleson & Bostrom in Terre Haute, Indiana. 21 3. The documents listed below and attached hereto as Exhibits 4-1 through 4-203 are true 22 and correct copies of news articles, postings, and other documents available on the Internet, as 23 they appeared when accessed by myself or my colleagues, with the exception of highlighting 24 which was added for the Court’s convenience in accordance with C.R. 10(e)(10). 25 26 27 28 First Decl. of Haynie in Supp. of 1 BOPP, COLESON & BOSTROM Pls.’ Mot. for Summ. J. 1 South Sixth Street (No. 3:09-CV-05456-BHS) Terre Haute, Indiana 47807 (812) 232-2434 Exhibit 4, Page 1 Case 3:09-cv-05456-BHS Document 210-1 Filed 06/29/11 Page 3 of 100 1 Internet Articles, Newspaper Articles, and Blog Postings 2 Ex. 4-1: Thomas M. Messner, The Price of Prop 8, Heritage Foundation Backgrounder, No. 2328, Oct. 22, 2009, available at 3 http://www.heritage.org/research/family/bg2328.cfm. 4 Ex. 4-2: John-Thomas Kobos, Proposition 8 Email Threats, KFSN-TV, Nov. 7, 2008, http://abclocal.go.com/kfsn/story?section=news/local&id=6494921. 5 Ex. 4-3: Andres Araiza, Prop 8 Threat: Fresno Police Close to Arrest, ABC-30 KFSN-TV, 6 Oct. 31, 2008, http://abclocal.go.com/kfsn/story?section=news/local&id=6479879. 7 Ex. 4-4: Declaration of Sarah E. Troupis in Support of Plaintiffs’ Motion for Summary Judgment, ProtectMarriage.com v. Bowen, No. 2:09-cv-00058 (E.D. Cal. filed June 8 3, 2009) [hereinafter Troupis Declaration, Bowen], Exhibit E (copy of a threatening communication described in Exs. 4-2 and 4-3). 9 Ex. 4-5: Amanda Perez, Prop 8 Death Threats, ABC Fresno, Oct. 31, 2008, 10 http://abclocal.go.com/kfsn/story?section=news/local&id=6479861&pt=print. 11 Ex. 4-6: Troupis Declaration, Bowen, Exhibit C (citing CBS47, Proposition 8 Death Threats, Oct. 31, 2008, 12 www.cbs47.tv/news/local/story/Proposition-8-Death-Threats/iQyK- 1E0C30aNjdD0tVyMJA.cspx). 13 Ex. 4-7: Adrienne S. Gaines, Radical Gay Activists Seek to Intimidate Christians, Charisma 14 Mag., Nov. 19, 2008, www.charismamag.com/index.php/news/19444. 15 Ex. 4-8: Colleen Raezler, O’Reilly Alone Reports Gay Attack on Christians, Culture and Media Institute (Nov. 19, 2008), http://www.mrc.org/cmi/articles/2008- 16 /OReilly_Alone_Reports_Gay_Attack_on_Christians_.html. 17 Ex. 4-9: KTVU, Anger over Prop. 8 Erupts in San Francisco, Nov. 14, 2008, http://www.ktvu.com/print/17986914/detail.html. 18 Ex. 4-10: Patrick B. Craine, Pro-marriage New York Senator Faces Death Threats, Barraged 19 with Hate Calls, Life Site News, June 7, 2011, http://www.lifesitenews.com/news/pro-marriage-new-york-senator-faces-death-thre 20 ats-barraged-with-hate-calls/. 21 Ex. 4-11: Andrew S., New York City: TNG Writing Contest Alert – “Fuck Ruben Diaz: Gay Erotica Featuring NYC’s Number One Bigot,” May 24, 2011, 22 http://thenewgay.net/2011/05/enter-ruben-diaz-fan-fiction-contest.html. 23 Ex. 4-12: Question 1 Backers Receive Death Threats, Former Homosexual Leader Says They Should Not Live in Fear, EWTN, Nov. 16, 2009, 24 http://www.ewtn.com/vnews/getstory.asp?number=98825. 25 Ex. 4-13: Karen S. Peterson, Man Behind the Marriage Amendment, USA Today, Apr. 12, 2004, http://www.usatoday.com/life/people/2004-04-12-matt-daniels_x.htm. 26 Ex. 4-14: Posting of JohnBisceglia, Referendums & Amendments—This Has to Stop NOW!, 27 to Queer Equality Revolution, Aug. 3, 2011, http://gaytaxprotest.blogspot.com/2009/08/gays-who-make-sense.html. 28 First Decl. of Haynie in Supp. of 2 BOPP, COLESON & BOSTROM Pls.’ Mot. for Summ. J. 1 South Sixth Street (No. 3:09-CV-05456-BHS) Terre Haute, Indiana 47807 (812) 232-2434 Exhibit 4, Page 2 Case 3:09-cv-05456-BHS Document 210-1 Filed 06/29/11 Page 4 of 100 1 Ex. 4-15: Krista Gesaman, Threats, Legal Action in Washington’s Gay-Marriage Debate, Newsweek, Sept. 8, 2009, 2 http://blog.newsweek.com/blogs/thegaggle/archive/2009/09/08/thr- eats-legal-action-in-washingtons-gay-marriage-debate.aspx. 3 Ex. 4-16: , Op-Ed., Gays Are Not the Nation’s New African Americans, 4 Seattle Times, Mar. 29, 2004, http:/ ty.seattletimes.nwsource.com/archive/?date=20040329&s- 5 lug= 29. 6 Ex. 4-17: Casey Sanchez, Anti-Gay Movement of Immigrant Fundamentalist Christians Threatens Western States, AlterNet, Oct. 5, 2007, 7 http://www.alternet.org/rights/64336/?page=4. 8 Ex. 4-18: Caryle Murphy & Hamil R. Harris, Thousands Rally on the Mall To Protest Same-Sex Marriage, Wash. Post, Oct. 16, 2004, at B01, available at 9 http://www.washingtonpost.com/ac2/wp-dyn/A36814-2004Oct15. 10 Ex. 4-19: Janet I. Tu, Outspoken Pastor a Spiritual Bulldozer?, Seattle Ti 5, 2005, http://seattletimes.nwsource.com/html/localnews/2002263363_ 05m.html. 11 Ex. 4-20: Lynn Thompson, Mount Si’s Gay-Rights Day of Silence Is Far from Quiet, Seattle 12 Times, Apr. 26, 2008, http://seattletimes.nwsource.com/html/eastsidenews/2004374870_dayofsilence26e.h 13 tml. 14 Ex. 4-21: Lynn Thompson, Mount Si’s Gay-Rights Day of Silence Is Far from Quiet, Seattle Times, Apr. 26, 2008, 15 http://seattletimes.nwsource.com/ABPub/zoom/html/2004374873.html (“Throw Rocks Here” picture). 16 Ex. 4-22: Seth Hemmelgarn, Prop 8 Fight Gets Ugly on Both Sides, Bay Area Rep., Oct. 16, 17 2008, http://www.ebar.com/news/article.php?sec=news&article=3403. 18 Ex. 4-23: Catholic News Agency, Attack Outside of Catholic Church Part of “Wave of Intimidation,” Says Yes on 8, Oct. 15, 2008, 19 http://www.catholicnewsagency.com/new.php?n=14069. 20 Ex. 4-24: Press Release, ProtectMarriage.com, Prop. 8 Supporter Violently Attacked for Distributing Lawn Signs, Oct. 13, 21 2008,http://www.protectmarriage.com/article/prop-8-sup- porter-violently-attacked-for-distributing-lawn-signs. 22 Ex. 4-25: David Markland, Prop 8 Supporter Attacked While Distributing Signs, NBC Los 23 Angeles, Jan. 7, 2008, http://www.nbclosangeles.com/news/politics/Prop_8_supporter_attacke- 24 d_while_distributing_signs_LA.html. 25 Ex. 4-26: TFP Student Action, Who We Are, http://www.tfpstudentaction.org/about-us/who-- we-are/who-we-are.html (last visited June 14, 2011). 26 Ex. 4-27: Bob Ellis, Homosexual Activists Assault Pro-Marriage Demonstration, Dakota 27 Voice, Mar. 29, 2011, http://www.dakotavoice.com/2011/03/homosexual-activists-assault-pro-marriag- 28 e-demonstration/. First Decl. of Haynie in Supp. of 3 BOPP, COLESON & BOSTROM Pls.’ Mot. for Summ. J. 1 South Sixth Street (No. 3:09-CV-05456-BHS) Terre Haute, Indiana 47807 (812) 232-2434 Exhibit 4, Page 3 Case 3:09-cv-05456-BHS Document 210-1 Filed 06/29/11 Page 5 of 100 1 Ex. 4-28: Brad Shannon, Vote on Partners Divides County, The Olympian, Oct. 18, 2009, http://www.theolympian.com/2009/10/18/v-print/1006573/vote-on-partners-divides- 2 county.html. 3 Ex. 4-29: Barbara Giasone, Five Held on Suspicion of Stealing “Yes” on Prop. 8 Signs, Orange County Reg., Oct. 21, 2008, 4 http://www.ocregister.com/articles/signs-macdonald-five-2201253-fullerton-sign. 5 Ex. 4-30: Sheriff: Prop. 8 Signs Being Stolen, Burned, KCRA Sacramento, Oct. 20, 2008, http://www.kcra.com/news/17758850/detail.html. 6 Ex. 4-31: Anthony Scorci, Sacto 9-1-1: Arrests Made in Roseville after Yes on Proposition 8 7 Signs Found in Car, Oct. 28, 2008, http://blogs.sacbee.com/crime/archives/2008/10/post-13.html. 8 Ex. 4-32: Salvador Hernandez, Prop. 8 Sign-Stealing Ignites Free Speech Debate, Orange 9 County Reg., Oct. 30, 2008, http://www.ocregister.com/articles/signs-stolen-people-2211707-prop- 10 osition-singam. 11 Ex.
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